Marriage changes a couple’s legal position in many ways. In Switzerland it has, for decades, also changed their tax bill – and not always in their favour. That arrangement is now being rewritten, in two steps, with one further vote still to come.
Dr Ariel Sergio Davidoff, Founding Partner of Davidoff Law in Zurich, contributed commentary on the Swiss tax reforms to Citywealth’s 2026 Switzerland private wealth update, published on 11 November 2026 alongside contributions from advisers in Geneva, Zurich, London and New York. The same update covers the new federal beneficial ownership register and the expanded anti-money laundering rules in force since 1 October 2026.
The wedding guest nobody invited
Under the system still in force, the incomes and assets of spouses are added together and taxed as one. Because federal tax rates are progressive, pooling two incomes can push a married couple into a higher bracket than an unmarried couple earning exactly the same amounts. As Davidoff puts it, «the wedding came with an uninvited guest: the taxman» – whose congratulations tended to arrive with a request for a cheque. The effect has been debated in Switzerland for more than three decades under the name Heiratsstrafe, the marriage penalty.
From 2032: two tax returns, one schedule
On 8 March 2026, 54.23 per cent of voters approved the federal act on individual taxation. From 1 January 2032 at the earliest, each spouse will file a separate return and be taxed on their own income and assets, attributed according to civil-law ownership, under a single federal tax schedule applying to everyone regardless of civil status. The cantons have been granted the longest preparation period the legislation allows. The effect on an individual household will vary: dual-income couples are generally expected to benefit, while single-income couples, and couples with a markedly uneven split of income, may find themselves worse off.
A second vote on 29 November 2026
The reform is not yet settled. On 29 November 2026, voters and cantons decide on the popular initiative «Ja zu fairen Bundessteuern auch für Ehepaare – Diskriminierung der Ehe endlich abschaffen!», which would anchor joint federal taxation of married couples in the constitution while prohibiting any tax disadvantage compared with other taxpayers. The initiative committee recommends acceptance; the Federal Council and Parliament recommend rejection, arguing that individual taxation has already removed the disadvantage and that two parallel systems would create uncertainty. Acceptance requires both a popular and a cantonal majority. Were the initiative to pass, couples could remain jointly assessed for federal tax while being taxed separately at cantonal and communal level from 2032, unless Parliament legislates otherwise – a complicated relationship, with rather more paperwork.
What this means for internationally mobile families
For families weighing a move to Switzerland, or already resident here, the practical point is the length of the transition. A relocation analysis built solely on the rules applying in the year of arrival may not reflect the position a household will actually face. Because income and assets will in future be attributed according to civil-law ownership, questions that once seemed purely private – the matrimonial property regime, which spouse holds which asset, how a family company or portfolio is allocated between them – acquire direct fiscal relevance. Cantonal and communal wealth tax, succession planning and the choice of canton all interact with these decisions, and the sensible moment to review them is well before 2032.
Please note: the full Citywealth update, including the commentary on the federal beneficial ownership register, the expanded AML rules and relocation trends, is available here:
Swiss Private Wealth Update 2026: Beneficial Ownership Register, Expanded AML Rules and Tax Reforms (Citywealth)
Further related insights from Ariel Davidoff and Davidoff Law are available here:
Steuerliche Fallgruben in der Nachfolge privater Unternehmen
Abschaffung des Eigenmietwerts – Quo Vadis?
Tücken bei der Nachlassplanung – Gleichbehandlung
Vorsorgen und Erben – Die Regeln des Vorsorgeauftrags
In short, Swiss couples are heading for a separation, at least on paper. Individual taxation ends a disadvantage that has outlived every attempt to justify it, but it also moves the tax conversation back into the household, where ownership, marital property and succession decide who is taxed on what. Whatever the outcome on 29 November, the direction of travel is clear enough to plan for.
